Local Plan 2011-2031 Proposed Submission Draft

We would like to comment with reference to the North Hertfordshire District Council's Local Plan 2011 - 2031 (Proposed Submission, October 2016) and specifically the massive proposed development at the Blackhorse Farm site to the north of Baldock. We are not opposed to houses being built in the area, in fact we are very much in favour. However the plans put forward by the Council are completely ill-advised, inappropriate and irresponsible and will mean an increase of 80% in the size of the town. This we believe will destroy the historic town of Baldock and its surrounding area.

Our objections are based on the two tests of soundness that local plans are required to meet:

1. Effective - the plan should be deliverable over its period and based on effective joint working on cross boundary strategic priorities;"
2. "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework

We do not believe that the Council has shown to the public and the residents of Baldock and surrounding villages that it has a deliverable plan in relation to:

* The volume of traffic in Baldock. There is a key area of traffic congestion in Baldock which has not been covered adequately by the Council - the junction where the A507 North Road meets the Royston Road. The junction is used by local traffic as well as a through route for all vehicles from surrounding main roads including the A1M. This is already a severe bottleneck especially at busy times - commuter rush hour, school runs etc. The junction cannot be widened due to listed building on either side of the junction. Therefore building a massive housing estate on the Blackhorse Farm estate will only make the current problems even more intolerable. The council has made little or no attempt to resolve this issue even though the National Planning Policy Framework clearly requires a Transport Assessment to be produced.

* Baldock Train Station. The town train station is situated between the congested junction (as raised in the previous point), and the railway embankment with its reduced access due to the railway bridge. The council does not appear to have taken into consideration that the building of 2,800 houses will put an intolerable strain on the station not least regarding parking and access at peak times of the day. It is expected that many people who will move into the new Blackhorse farm estate will work outside of Baldock - Cambridge, Stevenage, London etc. - and will use the local train station.

* As well as accessibility to the train station the capacity of the train station and the actual rail journeys capacity required to meet the commuter demand will be a significant issue if the Blackhorse Farm estate is built. The council has not indicated how this increase in capacity will be handled by the current station or indeed by the rail company who runs the rail franchise (Govia). The Council has not shown how they are working with Govia to deliver a sustainable plan. Indeed it appears that Govia are actually planning to reduce the overall Baldock service which indicates that the Council are not working "with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development"
as required by the National Planning Policy Framework.

* Road Infrastructure - Bypass connecting A507 and A505.
The council has proposed that a new bypass should be built connecting the A507 and the A505 (although as yet no plans have been produced. The proposed bypass will not address the issues raised in the previous paragraph as residents will need to access Baldock in order to use the railway station or alternatively use a station further up or down the line (which is unlikely). The full implications of the increased traffic on Baldock and the train station have not been fully considered by the Council.
The bypass, which will go through the Blackhorse farm estate, will inevitably lead to an "M25 effect" with traffic increasing as access is made easier from all points between the M1 through Ampthill and on to Royston and Cambridge. Once again we have seen no evidence that the Council has taken this likely effect into account

* The Council have not shown any realistic plans with regards to how the Baldock town infrastructure will be enhanced to take account of an 80% increase in size. The historic town of Baldock will be severely ravaged by this proposal and the Council has not shown the residents of Baldock and the surrounding impacted villages how it proposes to realistically cope with the proposed increase. What are the clear proposals for road infrastructure for the whole area, doctor surgeries, schools, impact on waste, water usage etc. The council has tried to put off all queries with meaningless platitudes and vague statements but unless there is a clear strategy and clear plans, the Blackhorse housing development could be given the go ahead without all the evidence and plans being made available for scrutiny.

* The proposed Blackhorse Farm development is on Green Belt land which is owned by the Council. It is in our opinion the ownership of the land that is driving the plans - it is a relatively easy and "cheap" decision for the Council to make without having to look for other more acceptable solutions. The council does not appear to have taken into account the National Planning Policy Framework covering the Green Belt. The Council plan will lead to urban sprawl which they are obliged to avoid. This proposal appears to ride roughshod over the Government's stated aim with regards to the Green Belt and that Councils should not build on Green Belt land merely to meet planning targets. The Council has failed to prove to Baldock residents that there are no alternative sites available rather than this massive development which will ostensibly double the size of Baldock but will not increase the required facilities to meet demand.

Conclusion

In our opinion the Council has failed to prove that it is meeting the "Tests of Soundness" that local plans are required to meet and has failed to develop an adequate strategy and detailed plans with regards to the impact of the Blackhorse Farm estate on Baldock, the surrounding villages and settlements, the overall road and rail infrastructure and the impact of the internal town infrastructure.

Baldock is already struggling with the traffic due to its historic buildings and road access which was not developed for modern day traffic volumes. To increase this by almost doubling the size of the town is completely unacceptable.

We are not against building houses in Baldock and the surrounding area but we are against a massive development with no clear strategy for the area which appears to be based on the main fact that the green belt farm land is owned by the Council and so can be used as they wish without taking into account local concerns and their statutory duty around the National Planning Policy Framework. The Council need to revisit their plans, dramatically reduce the size of the Blackhorse development and form a clear strategy and detailed plans in order to meet their requirements for the 2011 - 2031 Plans.

We would like to comment with reference to the North Hertfordshire District Council's Local Plan 2011 - 2031 (Proposed Submission, October 2016) and specifically the massive proposed development at the Blackhorse Farm site to the north of Baldock. We are not opposed to houses being built in the area, in fact we are very much in favour. However the plans put forward by the Council are completely ill-advised, inappropriate and irresponsible and will mean an increase of 80% in the size of the town. This we believe will destroy the historic town of Baldock and its surrounding area.

Our objections are based on the two tests of soundness that local plans are required to meet:

1. Effective - the plan should be deliverable over its period and based on effective joint working on cross boundary strategic priorities;"
2. "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework

We do not believe that the Council has shown to the public and the residents of Baldock and surrounding villages that it has a deliverable plan in relation to:

* The volume of traffic in Baldock. There is a key area of traffic congestion in Baldock which has not been covered adequately by the Council - the junction where the A507 North Road meets the Royston Road. The junction is used by local traffic as well as a through route for all vehicles from surrounding main roads including the A1M. This is already a severe bottleneck especially at busy times - commuter rush hour, school runs etc. The junction cannot be widened due to listed building on either side of the junction. Therefore building a massive housing estate on the Blackhorse Farm estate will only make the current problems even more intolerable. The council has made little or no attempt to resolve this issue even though the National Planning Policy Framework clearly requires a Transport Assessment to be produced.

* Baldock Train Station. The town train station is situated between the congested junction (as raised in the previous point), and the railway embankment with its reduced access due to the railway bridge. The council does not appear to have taken into consideration that the building of 2,800 houses will put an intolerable strain on the station not least regarding parking and access at peak times of the day. It is expected that many people who will move into the new Blackhorse farm estate will work outside of Baldock - Cambridge, Stevenage, London etc. - and will use the local train station.

* As well as accessibility to the train station the capacity of the train station and the actual rail journeys capacity required to meet the commuter demand will be a significant issue if the Blackhorse Farm estate is built. The council has not indicated how this increase in capacity will be handled by the current station or indeed by the rail company who runs the rail franchise (Govia). The Council has not shown how they are working with Govia to deliver a sustainable plan. Indeed it appears that Govia are actually planning to reduce the overall Baldock service which indicates that the Council are not working "with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development"
as required by the National Planning Policy Framework.

* Road Infrastructure - Bypass connecting A507 and A505.
The council has proposed that a new bypass should be built connecting the A507 and the A505 (although as yet no plans have been produced. The proposed bypass will not address the issues raised in the previous paragraph as residents will need to access Baldock in order to use the railway station or alternatively use a station further up or down the line (which is unlikely). The full implications of the increased traffic on Baldock and the train station have not been fully considered by the Council.
The bypass, which will go through the Blackhorse farm estate, will inevitably lead to an "M25 effect" with traffic increasing as access is made easier from all points between the M1 through Ampthill and on to Royston and Cambridge. Once again we have seen no evidence that the Council has taken this likely effect into account

* The Council have not shown any realistic plans with regards to how the Baldock town infrastructure will be enhanced to take account of an 80% increase in size. The historic town of Baldock will be severely ravaged by this proposal and the Council has not shown the residents of Baldock and the surrounding impacted villages how it proposes to realistically cope with the proposed increase. What are the clear proposals for road infrastructure for the whole area, doctor surgeries, schools, impact on waste, water usage etc. The council has tried to put off all queries with meaningless platitudes and vague statements but unless there is a clear strategy and clear plans, the Blackhorse housing development could be given the go ahead without all the evidence and plans being made available for scrutiny.

* The proposed Blackhorse Farm development is on Green Belt land which is owned by the Council. It is in our opinion the ownership of the land that is driving the plans - it is a relatively easy and "cheap" decision for the Council to make without having to look for other more acceptable solutions. The council does not appear to have taken into account the National Planning Policy Framework covering the Green Belt. The Council plan will lead to urban sprawl which they are obliged to avoid. This proposal appears to ride roughshod over the Government's stated aim with regards to the Green Belt and that Councils should not build on Green Belt land merely to meet planning targets. The Council has failed to prove to Baldock residents that there are no alternative sites available rather than this massive development which will ostensibly double the size of Baldock but will not increase the required facilities to meet demand.

Conclusion

In our opinion the Council has failed to prove that it is meeting the "Tests of Soundness" that local plans are required to meet and has failed to develop an adequate strategy and detailed plans with regards to the impact of the Blackhorse Farm estate on Baldock, the surrounding villages and settlements, the overall road and rail infrastructure and the impact of the internal town infrastructure.

Baldock is already struggling with the traffic due to its historic buildings and road access which was not developed for modern day traffic volumes. To increase this by almost doubling the size of the town is completely unacceptable.

We are not against building houses in Baldock and the surrounding area but we are against a massive development with no clear strategy for the area which appears to be based on the main fact that the green belt farm land is owned by the Council and so can be used as they wish without taking into account local concerns and their statutory duty around the National Planning Policy Framework. The Council need to revisit their plans, dramatically reduce the size of the Blackhorse development and form a clear strategy and detailed plans in order to meet their requirements for the 2011 - 2031 Plans.